VAT, Customs & Excises

EU packaging reform and France’s new commercial packaging EPR scheme

The European packaging landscape is undergoing its most significant transformation in decades. With the introduction of the Packaging and Packaging Waste Regulation (PPWR) and France’s new Extended Producer Responsibility (EPR) requirements for commercial packaging, companies operating in Europe must prepare for a new era of packaging compliance, reporting, recycling, and circular economy obligations.

For manufacturers, importers, distributors, e-commerce sellers, and logistics operators, 2026 will be a pivotal year.

Why packaging Is becoming a regulatory priority?

Packaging remains one of the largest sources of waste in Europe. According to the European Commission, packaging accounts for approximately 40% of plastics used in the EU, while packaging waste reached 186.5 kg per person in 2022. The growing volume of packaging waste has prompted policymakers to strengthen requirements across the entire packaging lifecycle, from design and production to collection and recycling.

To address these challenges, the EU adopted the Packaging and Packaging Waste Regulation (PPWR), creating a harmonized framework applicable across all Member States. The regulation entered into force on 11 February 2025 and will generally apply from 12 August 2026.

The PPWR: A new European framework for packaging

Unlike the previous Packaging and Packaging Waste Directive, the PPWR is a regulation, meaning it applies directly across the EU without requiring national transposition. The regulation covers all packaging and packaging waste regardless of material or sector and introduces requirements relating to:

  • Packaging design and composition
  • Reusability and recyclability
  • Waste prevention
  • Recycled content in packaging
  • Extended Producer Responsibility (EPR)
  • Harmonized reporting and registration obligations across Member States

Key objectives of the PPWR

The regulation aims to:

  • Ensure all packaging placed on the EU market is recyclable in an economically viable way by 2030.
  • Increase the use of recycled materials, particularly recycled plastics.
  • Reduce dependence on virgin raw materials.
  • Support the EU’s transition towards climate neutrality by 2050.

In addition, the PPWR introduces restrictions on certain single-use packaging formats and promotes reusable packaging systems across various sectors.

France expands EPR to commercial packaging

Alongside the EU-wide PPWR reforms, France is introducing a new EPR stream specifically targeting commercial and industrial packaging.

From 1 July 2026, companies placing commercial packaging on the French market will become subject to new producer responsibility obligations. The objective is to ensure that businesses contribute financially and operationally to the collection, sorting, and recycling of packaging waste generated in professional supply chains.

Who will be affected?

The French scheme is expected to impact companies that:

  • Supply products directly to professional customers in France.
  • Sell to French business customers through online marketplaces.
  • Deliver products to French distributors using packaging that enters French supply chains.

Which packaging is covered?

The future EPR scheme is expected to cover:

  • Sales packaging
  • Secondary or outer packaging
  • Grouped packaging
  • Transport packaging

For many businesses that have historically focused on household packaging obligations, this represents a significant expansion of compliance responsibilities.

Visual timeline: key packaging compliance milestones

What businesses should do now?

Although some implementation details are still being finalized, companies should begin preparing immediately.

1. Map your packaging flows

Identify every type of packaging placed on the French and EU markets, including transport and secondary packaging that may previously have been outside your compliance scope.

2. Review producer status

The PPWR broadens the concept of “producer” and may bring additional companies within the scope of registration and reporting requirements. Businesses should assess whether they will need registrations in multiple Member States or authorized representatives.

3. Prepare for data collection

Future reporting obligations will require accurate packaging data by material, weight, and packaging category. Companies should ensure internal systems can capture this information.

4. Monitor French EPR developments

As approved compliance schemes and fee structures become available, businesses should evaluate registration requirements and budget for future eco-contributions.

5. Evaluate packaging design

Organizations should review packaging portfolios now to ensure future compliance with recyclability, recycled content, and waste reduction requirements under the PPWR.

The combination of the EU Packaging and Packaging Waste Regulation and France’s new commercial packaging EPR regime marks a major shift in packaging compliance. Businesses that proactively assess their packaging obligations, improve data management, and prepare for new reporting requirements will be best positioned to avoid compliance risks and adapt smoothly to the circular economy framework taking effect from 2026 onward.

For companies placing packaging on the French market, the next months will be critical in building the processes necessary to meet both national EPR obligations and the broader requirements of the PPWR.

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